Privacy Policy

Issue 4 dated 11 March 2024

Purpose of this privacy policy

You have been granted access to our website and platform (our "Online Platform") and the services provided through our site (the "Services"). As part of the Services you will be providing us with information which may be about yourself, your peers, your employer or your suppliers ("Your Information”). This privacy policy aims to give you information on how any-3 collects and processes your personal data through your use of the Online Platform, including any data you may provide us when you take part in a survey.

The Services are provided by Any-3 Ltd (any-3, we, us and our). We are a limited company, registered in England. Our registered company number is 05485257, and our registered office is at 61 Elliscombe Road, Charlton, London, SE7 7PF.

You may be an employee or customer taking part in a survey either:

• as a customer giving feedback;
• as an employee being reviewed;
• as a peer respondent; or
• as an employee using our Services as a “Super User”, where you can gain access to certain reports relating to

This Online Platform is not intended for children and we do not knowingly collect data relating to children.

Data Processor

any-3 Limited is a data processor. We make our services available to you through your employer or a supplier you use, who will be the data controller in respect of your personal data. any-3 is not responsible for the privacy or security practices of your employer or supplier, which may differ from those set out in this privacy policy. Please check your employer's or suppliers privacy policy to confirm how they will treat your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact your employer’s data protection officer who will, if required, contact our data privacy manager.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact your employer’s data protection officer in the first instance.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, on behalf of your employer or supplier, which we have grouped together as follows:

Identity Data includes job title, job category, country of work, first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Online Platform.

Profile Data includes your username and password, preferences, feedback and survey responses.

Usage Data includes information about how you use our Online Platform and Services. The groups of personal data collected may include Special Categories of Personal Data.

Anonymity of results provided

We seek to protect the anonymity of all those taking part in using the Services. In particular we ensure in all reports on and analysis of the results of any survey that a minimum of six different individuals responses are combined before any report or segmentation is produced unless explicit permission has been given by you to share the detailed information you have submitted.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for a variety of purposes. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users who have completed the survey accessing a specific website feature.

How is your personal data collected?

We use different methods to collect data from, and about you, on behalf of your employer, or supplier including through:

Direct interactions: You may give us your Identity, Contact and Profile Data by registering for and completing a survey online or by using the helpline or otherwise. This includes personal data you provide when you:

• take part in a survey
• interact with our services; or
• give us feedback or contact

Automated technologies or interactions: As you interact with our Online Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

How we use your personal data

We will only use your personal data when the law allows us to and in accordance with the instructions of the data controller (employer or supplier).

Your employer or supplier, as the data controller, is responsible for determining the legal basis for processing your personal data, including the special categories of sensitive personal data outlined above. Please see your employer’s or suppliers privacy policy for more information.

Marketing

We do not use your personal data for marketing purposes, whether for promotion of any-3 or to promote third-parties.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Online Platform may become inaccessible or not functionproperly.

Our Online Platform uses cookies to distinguish you from other users of our Online Platform. This helps us to provide you with a good experience when you browse our Online Platform and allows us to improve our Online Platform.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Online Platform. They include, for example, cookies that enable you to log into secure areas of our Online Platform, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Online Platform when they are using it. This helps us to improve the way our Online Platform works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our Online Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our Online Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Online Platform.

Except for essential cookies, all other cookies will expire when your session ends or otherwise after two years.

Disclosures of your personal data

If you are an employee taking part in certain surveys, your personal data may be shared with your direct line manager. If you are unsure who this is then please contact your employer directly.

For most of our surveys however, your responses will be anonymised. Except with regards to the data sharing detailed below, your peer review responses will be anonymised and will be aggregated with responses from other peer reviews.

If you are a customer taking part in certain surveys, your personal data may be shared with your supplier (e.g. account manager) if you have given explicit consent as part of the survey. If you are unsure who this is then please contact your supplier directly.

External Third Parties

Service providers acting as processors based in the United Kingdom who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with your employer’s instructions.

International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data tothird countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US PrivacyShield.

Please contact your employer’s or suppliers data protection officer for further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify your employer or supplier as data controller of a breach where we are legally required to do so.

Data retention: How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of the Services you have accessed.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed Your Information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of your employer or supplier) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we, or your employer, has compelling legitimate grounds to process Your Information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal
• You have objected to our use of your data but we need to verify whether we, or your employer,

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for your employer or supplier to use or where we used the information to perform a contract with you.

If you wish to exercise any of the rights set out above, please contact your employer’s or suppliers’ data protection officer.

Contacting us, support and complaints

If you have any questions around the way Your Information is processed, then please cease to use the Services and contact your employer’s nominated data protection officer.

Making changes to the Privacy Policy

We reserve the right to change the terms of this Privacy Policy from time to time and you will be made aware that the terms have changed the next time you access the Online Platform. Your continued access or use of this Online Platform after such change signifies your acceptance of the updated or modified Privacy Policy.